SDBS

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This document is the final page (Page 9) of a legal letter dated September 12, 2013, written by attorney Jack Scarola. The text argues against the use of 'litigation privilege' to hide a 'life of perversion' and states that 'Epstein’s day of public reckoning is inevitable.' The letter references an upcoming mediation and copies several attorneys involved in the Epstein legal cases, including Bradley Edwards and Jack Goldberger.

Legal correspondence / letter (page 9)
2025-11-19

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This document is a page from a legal filing dated September 12, 2013, arguing that adverse inferences should be drawn from Jeffrey Epstein's refusal to answer questions during legal proceedings. It lists specific questions Epstein refused to answer regarding procuring minors for prostitution, sexual assaults on private planes, and assaults on victims L.M., E.W., and Jane Doe. The document asserts that the reasonable inference is that these allegations are true and that Epstein's counter-claims against attorney Mr. Edwards were motivated by extortion and malice.

Legal filing / motion summary (house oversight committee record)
2025-11-19

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This document is page 7 of a legal filing dated September 12, 2013, arguing that Jeffrey Epstein's use of the Fifth Amendment and obstructionist tactics (including securing lawyers for staff who recruited girls) creates an adverse inference of guilt. It states that attorney Bradley Edwards was pursuing discovery to prove Epstein was a 'serial molester' and discusses the admissibility of evidence regarding Epstein's abuse of other minors to establish modus operandi. The document cites case law supporting the use of adverse inferences in civil cases when a party refuses to testify.

Legal brief / court filing (page 7)
2025-11-19

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This legal document, dated September 12, 2013, outlines attorney Edwards' defense against Epstein's claims of improper litigation tactics. Edwards asserts he had a sound legal basis to pursue discovery and depositions from high-profile individuals—including Donald Trump, Bill Clinton, Alan Dershowitz, David Copperfield, and Bill Richardson—believing they possessed relevant information regarding Epstein's alleged sexual assaults. The document argues these individuals were identified as Epstein's 'close friends' and that seeking their testimony met the legal standard for discovery.

Legal filing / court document (likely a memorandum in support of summary judgment)
2025-11-19

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This document, dated September 12, 2013, is a legal defense of attorney Edwards against claims made by Jeffrey Epstein. It argues that Edwards did not 'pump' cases to investors, noting that he filed complaints against Epstein long before meeting Scott Rothstein or joining RRA. The text highlights that Epstein settled three cases (including one for 'Jane Doe') in July 2010 for significant sums via court-ordered mediation presided over by Judge Kenneth A. Marra, and that the Florida Bar dismissed Epstein's ethics complaint against Edwards.

Legal brief / motion argument (page 5 of a larger filing)
2025-11-19

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This document, dated September 12, 2013, appears to be a legal filing or summary defending attorney Bradley Edwards against claims made by Jeffrey Epstein. The text refutes Epstein's allegations that Edwards was involved in a Ponzi scheme run by Scott Rothstein, noting that Epstein failed to provide evidence during deposition and instead invoked attorney-client privilege. It also details that Edwards represents three victims (L.M., E.W., and Jane Doe) in civil suits against Epstein for sexual abuse.

Legal document / summary of proceedings
2025-11-19

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This document, dated September 12, 2013, appears to be page 3 of a legal summary or correspondence regarding a lawsuit filed by Jeffrey Epstein against attorney Edwards. The text details how Epstein refused to answer discovery questions regarding a victim identified as 'E.W.' and eventually dismissed his claims against Edwards just before a summary judgment hearing. The document strongly characterizes Epstein as a 'serial pedophile' who used the legal system to intimidate Edwards, who was representing three victims of sexual assault.

Legal document / legal correspondence (page 3 of a filing or letter)
2025-11-19

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This document is page 2 of a legal filing dated September 12, 2013, likely a brief supporting attorney Edwards' Motion for Summary Judgment against Jeffrey Epstein. The text argues that Epstein cannot sue Edwards for damages while simultaneously asserting his Fifth Amendment privilege ('sword and shield' doctrine) to avoid answering questions about his sexual abuse of minors, including specific allegations by victims L.M. and Jane Doe. It also reveals that Epstein settled three cases handled by Edwards for confidential amounts that were not of 'minimal value,' contradicting his own claims.

Legal motion/brief (likely in support of summary judgment)
2025-11-19

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This document is page 5 of a legal letter dated February 25, 2015, regarding discovery disputes in the case Edwards and Cassell v. Dershowitz. The text criticizes the Defendant (Dershowitz) for providing evasive, incomplete, or legally unfounded responses to interrogatories concerning his relationship with Jeffrey Epstein, statements made about Bradley Edwards, and potential witnesses. It specifically notes that Dershowitz refused to provide details based on flight logs or the deposition status of Jane Doe #3, and lists Thomas and Joanne Ashe as individuals identified by the Defendant.

Legal correspondence / discovery dispute letter
2025-11-19

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This document is page 4 of a legal letter dated February 25, 2015, from the law firm SDBS to Thomas E. Scott, Jr., regarding the case *Edwards and Cassell v. Dershowitz*. The letter aggressively challenges the defense's discovery responses, accusing them of 'word play and gamesmanship' regarding document production, metadata, and definitions. The sender demands immediate production of documents and rejects the defense's attempts to limit discovery to a narrow timeframe, arguing that Dershowitz's alleged defamation and public denials were broad and unrestricted by time.

Legal correspondence / court filing exhibit
2025-11-19

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This document is page 3 of a legal letter dated February 25, 2015, addressed to Thomas E. Scott, Jr. regarding the case *Edwards and Cassell v. Dershowitz*. The text outlines legal arguments concerning discovery abuses, specifically arguing that one cannot claim privilege or undue burden for documents that do not exist, and providing a broad legal definition of 'control' over documents to include those held by third parties like attorneys or accountants. The document was entered on the FLSD Docket on March 24, 2015, and bears a House Oversight Bates stamp.

Legal correspondence / court filing exhibit
2025-11-19
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